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Indian Education: Schools Need More Assistance to Provide Distance Learning
GAO-21-492T
Apr 28, 2021
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2 Open Recommendations
Agency Affected Recommendation Status
Bureau of Indian Education The Director of BIE should provide comprehensive guidance to schools on distance learning to ensure they have the information to create and maintain effective distance learning programs during extended school building closures. (Recommendation 1)
Open
BIE took some steps to support schools' online distance learning programs and used CARES Act funds to buy laptops and invest in IT infrastructure to help students with distance learning. However, BIE's limited guidance on distance learning for schools have impeded the agency's ability to ensure that schools can provide online distance learning when their buildings are closed to students. We will monitor BIE's efforts to address this challenge, which will help the agency ensure that schools have the information they need to deliver distance learning programs.
Bureau of Indian Education The Director of BIE should work with Indian Affairs' Office of Information Management Technology to develop and implement written policies and procedures for collecting timely information on BIE-operated schools' technology needs. (Recommendation 2)
Open
BIE took some steps to support schools' online distance learning programs and used CARES Act funds to buy laptops and invest in IT infrastructure to help students with distance learning. However, BIE's lack of policies and procedures for assessing schools' technology needs have impeded the agency's ability to ensure that schools can provide online distance learning when their buildings are closed to students. Collecting timely information on BIE-operated schools' technology needs would better position BIE to ensure that students have the technology to participate in these programs. We will monitor BIE's efforts to develop policies to collect this information.

Higher Education: IRS and Education Could Better Address Risks Associated with Some For-Profit College Conversions
GAO-21-89
Jan 27, 2021
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3 Open Recommendations
Agency Affected Recommendation Status
Internal Revenue Service The Commissioner of Internal Revenue should assess the agency's internal controls for reviewing for-profit college applications for tax-exempt status and improve the review process to ensure that staff appropriately apply agency guidance on assessing potential improper benefit to insiders. (Recommendation 1)
Open
IRS stated that it would assess its internal controls for reviewing applications for tax-exempt status from organizations with a for-profit history and make improvements to those controls, as appropriate. In July 2021, IRS stated that it had identified and was assessing internal controls for reviewing applications for tax-exempt status from organizations with a for-profit history. Specifically, IRS said it was reviewing relevant procedures for reviewing such cases, including technical review requirements. IRS said it was also reviewing relevant training materials to assure that appropriate technical training is provided to support accurate determinations of tax-exempt status. Based on the results of that assessment, IRS said it would consider updating internal controls, as appropriate. We appreciate IRS's efforts in this area and will update the status of this recommendation based on the results of IRS's assessment and resulting changes to its internal controls.
Internal Revenue Service The Commissioner of Internal Revenue should collect information, for instance on the annual IRS filing tax-exempt organizations are required to submit, that would enable the agency to systematically identify tax-exempt colleges with a for-profit history for audit and other compliance activities. (Recommendation 2)
Open
IRS stated it would evaluate the benefits and burdens of collecting information about the for-profit history of tax-exempt organizations, including colleges, and noted that it already asks tax-exempt organizations to report whether they have engaged in transactions with insiders. In July of 2021, IRS stated that it had reviewed relevant IRS forms and identified existing questions that capture information on the for-profit history of tax-exempt organizations and identify compliance issues that may be associated with for-profit conversions to tax-exempt status. IRS further reiterated that it would evaluate the benefits and burden of collecting any additional information. As we noted in our report, IRS forms do not capture information needed to isolate already approved tax-exempt organizations that have engaged in conversion transactions with insiders. As a result, IRS does not have the information it needs to systematically identify and audit approved tax-exempt organizations with a for-profit history--in particular, those that have engaged in for-profit college conversion transactions with insiders. We continue to believe that IRS should collect additional information to enable it to systematically identify tax-exempt organizations with a for-profit history--organizations that the agency acknowledges pose a heightened risk of improper benefit--for oversight purposes. We look forward to the results of IRS's assessment of the benefits and burdens of collecting additional information, and the actions it plans to take pursuant to its assessment.
Department of Education The Secretary of Education should develop and implement monitoring procedures for staff to review the audited financial statements of all newly converted nonprofit colleges for the risk of improper benefit. (Recommendation 3)
Open
Education agreed with this recommendation and said it would develop new financial analysis procedures to ensure that staff review audited financial statements submitted by newly converted colleges after Education's approval. In August 2021, Education provided an update on the status of its efforts to implement this recommendation, reiterating its commitment to developing new financial analysis procedures. The Department also noted that it was modifying decision letter templates to include additional reporting requirements for newly converted nonprofit colleges to include disclosure of amendments to servicing or contracting agreements, any new agreements with former owners or related parties, and the assumption of institutional responsibilities by other parties. Education noted that staff would monitor this information in addition to the colleges' audited financial statements. To demonstrate that new monitoring procedures have been finalized and implemented, as recommended, Education should provide GAO with updated monitoring procedures and examples of staff reviews that follow these procedures.

Higher Education: Department of Education Should Further Assess College Access Grant Programs
GAO-21-5
Jan 19, 2021
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2 Open Recommendations
Agency Affected Recommendation Status
Department of Education The Assistant Secretary for the Office of Postsecondary Education should take additional steps to ensure the performance data TRIO grantees report are reliable. (Recommendation 1)
Open
Education partially concurred with this recommendation. Education agreed that this information is important and the department has an interest in improving its reliability, noting steps it could take to better monitor the reliability of the different types of performance data grantees submit. However, Education noted that it does not have access to underlying data sources that can independently verify certain data that grantees in some programs are required to submit, such as high school persistence, rigorous course enrollment, exposure to research opportunities, student grade point average, and secondary school completion. We recognize that Education may not have access to all of the underlying data. However, verifying information where possible is an important step toward improving oversight of grantees. In addition, Education could ask grantees to explain how they collect data and request related documentation. Education stated that it could require grantees to explain their methodology for compiling student level data. Such action could help identify data reliability concerns even in cases where independent verification is more difficult. Education also noted that its ability to verify data submitted by grantees is dependent on the availability of appropriate funds for staffing. However, many of the steps the department identified to better monitor data reliability may not necessarily require additional staffing costs, such as leveraging the department's existing internal data or requiring grantees to document their methodology. Further, Education could consider other ways to limit costs, such as through a risk-based approach of monitoring a sample of grantees' performance data. Prioritizing staff resources toward oversight and monitoring is an essential component of program administration, particularly for programs like TRIO that rely on the results of prior performance to award future grants. We will monitor the agency's progress to ensure the reliability of TRIO grantee performance data.
Department of Education The Assistant Secretary for the Office of Postsecondary Education should develop a plan—with specific actions and milestone dates—for assessing the effectiveness of TRIO programs that serve students using methods that are consistent with its statutory authority. (Recommendation 2)
Open
Education agreed with this recommendation. The agency stated that it plans to evaluate TRIO programs using the most rigorous methods available given statutory limitations and will develop a plan with specific actions and milestone dates. Education also noted that it is mindful of the statutory limitations of the HEA, under which Education cannot require grantees to participate in an evaluation that requires TRIO grantees to recruit additional students beyond those the TRIO program or project would normally recruit or that results in the denial of services for an eligible student under the program or project. We will monitor the agency's progress on these efforts.

Native American Youth: Agencies Incorporated Almost All Leading Practices When Assessing Grant Programs That Could Prevent or Address Delinquency [Reissued with revisions on Aug. 27, 2020.]
GAO-20-600
Aug 27, 2020
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3 Open Recommendations
Agency Affected Recommendation Status
Administration for Children and Families The Associate Commissioner of the Administration for Children and Families Children's Bureau within the Department of Health and Human Services should develop a process to assess the reliability of grantee performance information contained within annual performance reports for tribal recipients of its Stephanie Tubbs Jones Child Welfare Services Program. (Recommendation 1)
Open
The Department of Health and Human Services (HHS) did not concur with this recommendation. We continue to believe that the recommendation is valid because assessing the reliability of grantee performance information from tribal recipients could help provide the HHS Administration for Children (ACF) and Families Children's Bureau further assurance that it has an accurate representation of grantee performance. HHS stated that the ACF Children's Bureau's joint planning process with tribes to develop a plan to implement the Stephanie Tubbs Jones Child Welfare Services Program is sufficient to assess the reliability of grantee performance information and that any additional activities would be overly burdensome and resource intensive. We acknowledge HHS's statement that this joint process may be used to assess the reliability of any grantee performance information, generally. However, assessing grantee performance information for tribal recipients contained within annual performance reports, specifically, is important since these reports are where tribal recipients provide updates on the progress they made toward the goals and objectives set forth during the joint planning process. We will continue to monitor HHS's efforts to address this recommendation.
Bureau of Indian Education The Director of the Department of the Interior's Bureau of Indian Education should take steps to alert grantees of the Native Language Immersion Cooperative Agreement when they are late in submitting performance reports. (Recommendation 2)
Open
The Department of Interior's Bureau of Indian Education (BIE) concurred with this recommendation and stated that it should be able to address the recommendation as the BIE office that administers the Native Language Immersion Cooperative Agreement matures and fills critical vacancies. When we confirm what actions the BIE has taken in response to this recommendation, we will provide updated information.
Bureau of Indian Education The Director of the Department of the Interior's Bureau of Indian Education should develop a process to assess the quality and reliability of a sample of grantee performance data for the Native Language Immersion Cooperative Agreement. (Recommendation 3)
Open
The Department of Interior's Bureau of Indian Education (BIE) concurred with this recommendation and stated that it would take steps to implement it. When we confirm what actions the BIE has taken in response to this recommendation, we will provide updated information.
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